1. Policy Statement
Al-Waris Foundation is committed to safeguarding and promoting the welfare of every child who comes into contact with the charity through its activities, services, projects, events, communications, partnerships or other work.
For the purposes of this policy, a child is anyone under the age of 18.
Al-Waris Foundation recognises that safeguarding is everyone's responsibility.
The Board of Trustees has ultimate responsibility for safeguarding within the charity. Operational safeguarding responsibilities may be delegated to appropriately appointed individuals, but the trustees retain overall responsibility for ensuring that safeguarding risks are identified, managed and reviewed.
Al-Waris Foundation will take reasonable and proportionate steps to prevent harm and will respond promptly and appropriately where a safeguarding concern arises.
The welfare and best interests of the child will be a primary consideration in safeguarding decisions.
2. Scope
This policy applies to:
- trustees;
- staff;
- volunteers;
- contractors;
- consultants;
- representatives;
- project workers;
- fundraisers acting on behalf of Al-Waris Foundation;
- delivery partners where relevant;
- any other person acting on behalf of the charity.
It applies to Al-Waris Foundation activities:
- in the United Kingdom;
- overseas;
- online;
- in person;
- at charity premises;
- at events;
- during fundraising;
- during project delivery;
- during visits to beneficiaries;
- when taking photographs or video;
- when communicating electronically with children;
- when working through partner organisations or contractors.
3. Our Safeguarding Principles
Al-Waris Foundation will:
- treat the safety and welfare of children as a priority;
- respect the dignity, rights, wishes and feelings of children;
- take concerns seriously and respond without unnecessary delay;
- provide appropriate and accessible ways for safeguarding concerns to be raised;
- not discriminate when responding to safeguarding concerns;
- recognise that some children may face additional barriers to reporting abuse or accessing support;
- recruit and select people safely for roles involving children;
- provide safeguarding information, training and supervision proportionate to people's roles;
- maintain appropriate professional boundaries;
- share safeguarding information where necessary, lawful and proportionate;
- maintain appropriate safeguarding records;
- report concerns to statutory authorities where required or appropriate;
- cooperate with safeguarding authorities;
- manage safeguarding risks associated with partners and overseas operations;
- learn from safeguarding incidents, concerns and near misses.
4. Legal and Regulatory Framework
This policy should be read in the context of applicable law and guidance, including where relevant:
- Children Act 1989;
- Children Act 2004;
- Working Together to Safeguard Children 2026;
- Safeguarding Vulnerable Groups Act 2006;
- Protection of Freedoms Act 2012;
- Rehabilitation of Offenders Act 1974 and applicable exceptions;
- Data Protection Act 2018;
- UK General Data Protection Regulation;
- Equality Act 2010;
- Human Rights Act 1998;
- relevant Disclosure and Barring Service requirements;
- Charity Commission safeguarding guidance;
- Charity Commission serious incident reporting guidance.
Where Al-Waris Foundation operates outside the United Kingdom, applicable local safeguarding law and reporting requirements must also be considered.
Where local law provides a lower level of protection than this policy, Al-Waris Foundation should seek to maintain the standards contained in this policy so far as lawful and reasonably practicable.
5. Definitions
5.1 Safeguarding
Safeguarding means taking reasonable steps to protect children from abuse, neglect, exploitation and other forms of harm and responding appropriately when concerns arise.
5.2 Abuse
Abuse may include, but is not limited to:
- physical abuse;
- emotional abuse;
- sexual abuse;
- neglect;
- exploitation;
- child sexual exploitation;
- child criminal exploitation;
- trafficking;
- modern slavery;
- domestic abuse;
- coercive or controlling behaviour;
- online abuse;
- grooming;
- bullying and cyberbullying;
- discriminatory abuse;
- financial exploitation;
- forced marriage;
- so-called honour-based abuse;
- female genital mutilation;
- radicalisation or exploitation for extremist purposes.
A child may experience more than one type of abuse at the same time.
Abuse may occur in person or online and may be perpetrated by adults or other children.
6. Roles and Responsibilities
6.1 Board of Trustees
The Board of Trustees has ultimate responsibility for safeguarding.
The Board will:
- approve this policy;
- ensure safeguarding risks are considered as part of the charity's risk management;
- ensure appropriate safeguarding arrangements are maintained;
- receive appropriate safeguarding assurance and reporting;
- ensure serious incidents are considered for reporting to the Charity Commission where required;
- ensure appropriate action is taken when safeguarding failures are identified;
- review safeguarding arrangements at least annually.
6.2 Designated Safeguarding Lead
Al-Waris Foundation will appoint a Designated Safeguarding Lead (DSL).
The DSL is responsible for coordinating operational safeguarding arrangements.
Responsibilities include:
- receiving safeguarding concerns;
- providing safeguarding advice;
- maintaining appropriate safeguarding records;
- determining appropriate escalation;
- making or coordinating referrals to statutory authorities where appropriate;
- ensuring safeguarding concerns are followed up;
- supporting safeguarding training and awareness;
- informing the Board of significant safeguarding matters while maintaining appropriate confidentiality;
- maintaining knowledge of relevant safeguarding procedures.
The identity and current contact details of the DSL should be maintained in the charity's controlled organisational records and made available to everyone who needs them.
6.3 Deputy Safeguarding Arrangements
Where practicable, Al-Waris Foundation should appoint a deputy or alternative safeguarding contact.
Where the DSL is unavailable, concerns must not be delayed unnecessarily.
6.4 Trustee Safeguarding Oversight
The Board may appoint a Trustee Safeguarding Lead to provide additional Board-level oversight.
Appointment of a Trustee Safeguarding Lead does not remove the collective responsibility of the Board.
6.5 Everyone Acting for Al-Waris Foundation
Everyone covered by this policy must:
- understand the safeguarding requirements relevant to their role;
- follow this policy and related procedures;
- maintain appropriate boundaries;
- report safeguarding concerns promptly;
- cooperate with safeguarding enquiries;
- not conduct their own investigation into suspected abuse unless specifically authorised as part of an appropriate process.
7. Responding to Immediate Danger
If a child is in immediate danger or requires urgent medical attention:
- contact the appropriate emergency service without delay;
- take reasonable steps to protect the child without placing yourself or others at unnecessary risk;
- inform the Designated Safeguarding Lead as soon as reasonably practicable;
- make an accurate written record of what occurred.
In the United Kingdom, an emergency should normally be reported using 999 or 112.
For overseas activities, the relevant local emergency arrangements should be used.
Safeguarding action must not be delayed simply because an internal charity contact is unavailable.
8. Recognising a Safeguarding Concern
A concern may arise because:
- a child makes a disclosure;
- an adult reports a concern;
- a volunteer, trustee or staff member witnesses something;
- a child's behaviour or appearance causes concern;
- an allegation is made against someone associated with the charity;
- inappropriate communications are discovered;
- photographs, video or online content raise concerns;
- a partner organisation reports an incident;
- information is received from a statutory authority;
- a pattern of smaller concerns indicates a potentially greater risk.
A person does not need proof that abuse has occurred before reporting a safeguarding concern.
Reasonable concern is sufficient.
9. Responding to a Disclosure
If a child tells you that they have been harmed or are at risk of harm:
Do:
- remain calm;
- listen carefully;
- take the child seriously;
- allow the child to speak in their own words;
- reassure them that they were right to speak up;
- explain that you may need to share information with people who can help;
- make an accurate record as soon as possible;
- report the matter promptly to the DSL or appropriate authority.
Do not:
- promise absolute confidentiality;
- investigate the allegation yourself;
- interrogate the child;
- ask unnecessary or leading questions;
- confront the alleged perpetrator;
- make assumptions;
- delay reporting because you are uncertain.
Where clarification is essential, questions should be minimal and open, for example:
"What happened?"
rather than questions that suggest an answer.
10. Reporting a Safeguarding Concern
Safeguarding concerns should normally be reported to the Designated Safeguarding Lead as soon as possible.
The report should include, where known:
- name of the child;
- date of birth or approximate age;
- contact information where appropriate;
- date and time of the concern;
- location;
- people involved;
- factual description of what was seen, heard or disclosed;
- exact words used where significant;
- immediate action taken;
- name of the person making the report.
If the DSL is unavailable and delay could increase risk, the person receiving the concern should contact the appropriate statutory authority directly.
11. Concerns About the Designated Safeguarding Lead or Senior Person
If a safeguarding allegation concerns the Designated Safeguarding Lead, it should be reported to the Chair or Trustee Safeguarding Lead.
If it concerns the Chair, it should be reported to another unconflicted trustee.
If it concerns multiple trustees or there is reason to believe that internal reporting would place someone at further risk, the concern should be raised directly with the appropriate statutory authority and, where appropriate, the Charity Commission.
No person should be expected to report an allegation solely to the individual who is the subject of that allegation.
12. Referrals and External Reporting
The DSL will consider whether a concern should be referred to:
- local authority children's social care;
- police;
- Local Authority Designated Officer (LADO), where applicable;
- Disclosure and Barring Service;
- Charity Commission;
- another regulator;
- overseas safeguarding or law-enforcement authorities;
- another appropriate specialist agency.
The charity will not attempt to replace statutory safeguarding authorities.
Where there is uncertainty about whether a referral should be made, appropriate safeguarding advice should be obtained.
13. Allegations Against Trustees, Staff, Volunteers or Representatives
Any allegation that a person acting for Al-Waris Foundation has:
- harmed a child;
- potentially committed an offence against a child;
- behaved towards a child in a way that indicates they may pose a risk;
- seriously breached professional boundaries;
must be treated as a safeguarding matter.
The charity may take interim protective measures while the matter is assessed.
These may include:
- removing the person from direct contact with children;
- altering duties;
- suspending access to systems or premises;
- temporary suspension from duties.
Such measures are precautionary and do not themselves determine guilt.
The charity must consider whether external authorities should be notified before beginning any internal investigation.
An internal disciplinary or governance process must not interfere with a police or statutory safeguarding investigation.
14. Safer Recruitment
Roles involving children must be assessed for safeguarding risk before recruitment.
Al-Waris Foundation will undertake checks proportionate to the role, which may include:
- identity verification;
- application forms;
- interviews;
- references;
- examination of unexplained gaps;
- qualification checks;
- right-to-work checks where applicable;
- criminal record checks where legally available and appropriate;
- overseas checks where appropriate;
- safeguarding questions;
- conflict-of-interest declarations.
DBS checks must only be requested at a level for which the role is legally eligible.
A DBS certificate alone does not establish that someone is suitable to work with children.
Safer recruitment must be combined with appropriate induction, supervision, training and ongoing safeguarding management.
See the Al-Waris Foundation Safer Recruitment Policy.
15. Code of Conduct and Professional Boundaries
People acting for Al-Waris Foundation must maintain appropriate boundaries with children.
They must not:
- engage in sexual or romantic conduct with a child;
- make sexualised comments;
- engage in inappropriate physical contact;
- deliberately create unnecessary situations where they are isolated with a child;
- exchange inappropriate gifts;
- use degrading, discriminatory or humiliating language;
- engage in inappropriate private electronic communication;
- request or share sexual or otherwise inappropriate images;
- exploit a child financially, emotionally or otherwise;
- use their charitable position to obtain personal benefit from a child or family.
Physical contact should be appropriate, proportionate and related to a legitimate activity or safeguarding need.
16. One-to-One Contact
Where reasonably practicable, activities involving children should be organised to avoid unnecessary unsupervised one-to-one situations.
Where one-to-one contact is necessary:
- it should have a legitimate purpose;
- appropriate safeguards should be in place;
- the environment should be observable where practicable;
- another responsible person should know that the contact is occurring;
- records should be maintained where appropriate.
The charity will assess supervision arrangements according to the nature of the activity, age and needs of the children involved and the environment.
17. Online Safeguarding
This policy applies equally to online activity.
People acting for Al-Waris Foundation must not use digital communications to develop inappropriate private relationships with children.
Where communication with a child is necessary:
- official channels should be used where reasonably practicable;
- communication should relate to legitimate charity activity;
- parents or carers should be involved where appropriate;
- unnecessary private messaging should be avoided;
- messages must remain professional;
- disappearing-message functions should not be used for official safeguarding-sensitive communications where records may be required.
Safeguarding concerns arising online must be reported in the same way as offline concerns.
18. Photography and Video
Al-Waris Foundation may use photographs and video to document projects, demonstrate accountability and communicate charitable work.
The dignity and safety of children must take priority over content creation or fundraising.
Before identifiable images of children are intentionally captured or published, appropriate consent or other lawful authority must be established according to the circumstances.
Where appropriate:
- parental or carer consent should be obtained;
- the child's wishes should be respected;
- unnecessary identifying information should not accompany images;
- images should not be degrading, exploitative or sexualised;
- sensitive locations and personal circumstances should not be disclosed unnecessarily;
- geolocation or other identifying metadata should be considered;
- images should be stored securely.
A child should not be pressured to participate in photography or video as a condition of receiving charitable assistance.
See the Photography, Video and Beneficiary Consent Policy.
19. Dignity in Humanitarian Communications
Children and families must be represented with dignity.
Al-Waris Foundation will avoid communications that:
- unnecessarily humiliate beneficiaries;
- sensationalise suffering;
- portray children merely as fundraising objects;
- reveal sensitive personal circumstances without justification;
- create unreasonable safeguarding risks.
Where illustrative or AI-generated material is used, it must not be falsely represented as evidence of an actual beneficiary, project or completed charitable activity.
20. Overseas Activities
Safeguarding obligations apply to Al-Waris Foundation's overseas activities.
Before activities involving children are undertaken overseas, the charity should consider:
- local safeguarding risks;
- local laws;
- emergency contacts;
- referral routes;
- partner safeguarding arrangements;
- suitability of contractors and volunteers;
- supervision;
- photography and communications;
- transportation;
- accommodation where relevant;
- language and accessibility;
- cultural practices that may affect safeguarding;
- risks of exploitation, trafficking or abuse;
- procedures where local authorities cannot safely or effectively respond.
Safeguarding standards must not be abandoned because an activity takes place outside the UK.
21. Partners, Contractors and Third Parties
Where Al-Waris Foundation works through another organisation, contractor or project partner, safeguarding must form part of proportionate due diligence.
Depending on the nature of the arrangement, this may include:
- reviewing the partner's safeguarding policy;
- confirming safeguarding contacts;
- assessing recruitment practices;
- agreeing incident-reporting requirements;
- including safeguarding terms in agreements;
- monitoring compliance;
- requiring prompt notification of serious safeguarding concerns.
Al-Waris Foundation should not knowingly fund or continue working with an organisation that presents an unacceptable safeguarding risk without effective mitigation.
See the Overseas Operations and Partner Due Diligence Policy where applicable.
22. Events and Activities
Activities involving children must be appropriately planned.
Consideration should be given to:
- supervision;
- age and needs of participants;
- consent;
- attendance records;
- emergency contacts;
- first aid;
- accessibility;
- transport;
- collection arrangements;
- toilets and changing areas where relevant;
- photography;
- online communications;
- venue safety;
- lost or missing children;
- behaviour management;
- safeguarding reporting.
A written risk assessment should be completed where appropriate to the nature and level of risk.
23. Transport
Where Al-Waris Foundation arranges transport involving children:
- drivers must be appropriately licensed and insured;
- vehicles must be suitable and roadworthy;
- seatbelt and child-restraint requirements must be followed;
- unnecessary one-to-one transport should be avoided;
- collection and destination arrangements should be clear;
- safeguarding risks should be assessed.
24. Behaviour Management
Children must be treated respectfully.
Corporal punishment, degrading punishment, humiliation and abusive disciplinary practices are prohibited.
Any physical intervention must be limited to circumstances where it is lawful, necessary and proportionate to prevent immediate harm.
Any significant physical intervention involving a child must be recorded and reported.
25. Bullying and Peer-on-Peer Harm
Al-Waris Foundation will take reasonable steps to prevent and respond to:
- bullying;
- cyberbullying;
- sexual harassment;
- sexual violence;
- discriminatory abuse;
- coercion;
- intimidation;
- exploitation;
- harmful behaviour between children.
Harmful behaviour between children must not be dismissed as "banter" or normal behaviour merely because those involved are of similar age.
26. Missing Child
If a child goes missing during an Al-Waris Foundation activity:
- immediately alert the activity leader;
- establish when and where the child was last seen;
- search only where this can be done safely and without compromising supervision of other children;
- contact parents/carers where appropriate;
- contact police or emergency services where necessary;
- inform the DSL;
- record and review the incident.
27. Information Sharing
Safeguarding information must be handled carefully but concerns about confidentiality must not prevent necessary action to protect a child.
Information should be shared:
- for a legitimate safeguarding purpose;
- with people who need it;
- on a proportionate basis;
- accurately;
- securely;
- with an appropriate record of the decision.
Consent should be considered where appropriate, but safeguarding information may need to be shared without consent where there is a lawful basis and doing so is necessary to protect a child or another person.
See the Data Protection and UK GDPR Policy and Confidentiality Policy.
28. Safeguarding Records
Safeguarding records must:
- be factual;
- distinguish fact from opinion;
- record dates and times;
- record actions and decisions;
- record reasons for significant decisions;
- be stored securely;
- have access restricted to authorised persons;
- be retained in accordance with legal, safeguarding and records-management requirements.
Safeguarding records should not be stored casually in personal messaging accounts or personal devices where an approved secure system is available.
29. Confidentiality
Safeguarding information is confidential but not absolutely confidential.
Information may be shared where:
- a child is at risk;
- another person may be at risk;
- disclosure is required by law;
- a statutory safeguarding authority requires information;
- sharing is otherwise necessary and lawful for safeguarding purposes.
People receiving safeguarding information should only receive what is necessary for their role.
30. Data Protection
Personal data processed for safeguarding purposes must be handled in accordance with the Data Protection Act 2018 and UK GDPR.
Safeguarding records may include special category data and criminal offence data and therefore require particularly careful handling.
The charity must identify an appropriate lawful basis and, where applicable, a condition for processing such information.
Data protection must support appropriate safeguarding and should not be incorrectly used as a reason to avoid necessary safeguarding action.
31. Serious Incident Reporting
Safeguarding incidents may also constitute serious incidents for charity regulatory purposes.
The Board of Trustees is responsible for ensuring that consideration is given to whether a serious incident report should be made to the Charity Commission.
The charity should not delay necessary safeguarding referrals while deciding whether a Charity Commission report is required.
See the Serious Incident Reporting Policy.
32. Disclosure and Barring Service Referrals
Where the legal criteria for a referral to the Disclosure and Barring Service are met, Al-Waris Foundation will make the required referral.
A DBS referral is separate from reporting a matter to the police, local authority or Charity Commission.
The charity will seek appropriate advice where the referral duty is unclear.
33. Whistleblowing
Trustees, staff and volunteers must be able to raise genuine safeguarding concerns without fear of retaliation.
Concerns about wrongdoing, concealment of safeguarding failures or inappropriate handling of an allegation may also be raised under the Whistleblowing Policy.
No person will be penalised for raising a genuine safeguarding concern in good faith, even if the concern is ultimately not substantiated.
Malicious allegations knowingly made in bad faith may be dealt with separately.
34. Complaints
Complaints about the charity's safeguarding practices may be raised through the Complaints Policy.
However, an allegation of abuse or immediate safeguarding risk must be dealt with through safeguarding procedures and must not be delayed while an ordinary complaint is processed.
35. Training
Safeguarding training will be proportionate to the person's role.
People who regularly work directly with children or manage safeguarding concerns should receive more detailed training than those with limited contact.
Training may include:
- recognising abuse;
- responding to disclosures;
- reporting concerns;
- professional boundaries;
- online safeguarding;
- photography;
- information sharing;
- safer recruitment;
- overseas safeguarding where relevant.
Safeguarding training should be refreshed periodically and when significant changes to responsibilities or guidance occur.
36. Induction
Relevant trustees, staff and volunteers should receive safeguarding information during induction.
This should include:
- this policy;
- how to report a concern;
- identity of safeguarding contacts;
- expected standards of conduct;
- confidentiality;
- emergency procedures;
- role-specific safeguarding requirements.
37. Monitoring and Assurance
The Board will receive proportionate safeguarding assurance.
This may include anonymised information about:
- safeguarding concerns;
- incidents;
- referrals;
- training;
- safer recruitment;
- complaints;
- partner safeguarding;
- overdue actions;
- policy compliance;
- emerging risks.
Safeguarding reporting to trustees must protect confidentiality and avoid unnecessary disclosure of personal information.
38. Policy Breaches
Failure to comply with this policy may result in action including:
- additional training;
- removal from an activity;
- restriction of duties;
- disciplinary action where applicable;
- termination of a volunteer or contractual relationship;
- removal from office where lawful and applicable;
- referral to safeguarding authorities;
- referral to regulators or professional bodies;
- referral to police.
The response will depend on the nature and seriousness of the breach.
39. Related Al-Waris Foundation Policies
This policy should be read alongside, where applicable:
- Safeguarding Adults at Risk Policy;
- Safer Recruitment Policy;
- Volunteer Policy;
- Trustee Code of Conduct;
- Complaints Policy;
- Whistleblowing Policy;
- Serious Incident Reporting Policy;
- Data Protection and UK GDPR Policy;
- Confidentiality Policy;
- Information Security and Cybersecurity Policy;
- Photography, Video and Beneficiary Consent Policy;
- Social Media and Digital Communications Policy;
- Overseas Operations and Partner Due Diligence Policy;
- Health and Safety Policy;
- Risk Management Policy;
- Conflict of Interest Policy.
40. Review
This policy will be reviewed:
- at least annually;
- following a serious safeguarding incident;
- following a significant safeguarding concern or identified policy failure;
- following a material change in Al-Waris Foundation's activities;
- where the charity begins operating in a materially different environment or country;
- following significant changes to relevant law, regulation or statutory guidance.
Changes must be approved in accordance with Al-Waris Foundation's governance arrangements.
41. Approval
Version: 2.0 Status: Approved Approved by: Board of Trustees Approval date: 25/08/2026 Next scheduled review: 24/08/2027
